PPN 009 Tackling Modern Slavery in Government Supply Chains: the official note, explained

The key facts

• PPN 009 is an information note first issued in February 2023 and updated in February 2025.
• It applies to all central government departments, their executive agencies, non-departmental public bodies and NHS bodies awarding public contracts for goods, services or works, other than special regime contracts.
• Other public sector contracting authorities may choose to apply the same approach.
• The update reflects new terminology introduced by the Procurement Act 2023 and the Procurement Regulations 2024, which apply to procurements commenced on or after 24 February 2025.
• For procurements commenced and contracts awarded before 24 February 2025, the note directs readers back to PPN 02/23.
• In-scope organisations must use the PPN 009 guidance to identify and manage modern slavery risks in both new procurement activity and existing contracts.
• Risk assessment characteristics have been updated to reflect current global risks in sectors of concern including cotton, PPE and polysilicon.
• There is a requirement for supply chain information to be provided for new procurements designated as high risk of modern slavery, plus guidance on enhanced due diligence and on using existing exclusion grounds more effectively.

What PPN 009 is and who it applies to

PPN 009 is the current information note on tackling modern slavery in government supply chains. It was previously issued in February 2023 and updated in February 2025. Modern slavery is used in the note as an umbrella term covering slavery, servitude, forced and compulsory labour and human trafficking. The government position is that departments must take action so that modern slavery risks are identified and managed effectively in the supply chains that serve public contracts.

The note applies to all central government departments, their executive agencies, non-departmental public bodies and NHS bodies when awarding public contracts for goods, services or works, other than special regime contracts. These bodies are called in-scope organisations throughout. Wider public sector contracting authorities are not bound by the note but may wish to apply the same approach, and many do because the underlying risk does not respect organisational boundaries.

The note asks organisations to circulate it internally, particularly to people in commercial, procurement and contract management roles, and notes it may also be relevant to finance, operational and sustainability colleagues. That distribution list matters: the practical work of modern slavery risk management sits as much with the people running live contracts as with the people running competitions.

What the note requires

The core action is unambiguous. In-scope organisations must use the accompanying document, PPN 009 Guidance: Tackling Modern Slavery in Government Supply Chains, to identify and manage risks in both new procurement activity and existing contracts. The guidance is not optional background reading for in-scope bodies; it is the mechanism by which the policy is applied.

Three further points are flagged for attention. First, the characteristics used for assessing the risk of modern slavery in procurements have been updated to include current global modern slavery risks in key sectors of concern, and the note names cotton, PPE and polysilicon as examples. Second, there is a requirement for supply chain information to be provided for new procurements designated as having a high risk of modern slavery. Third, there is additional guidance on enhanced due diligence activities and on using existing exclusion grounds more effectively.

Taken together these push the work upstream and downstream at the same time. Upstream, risk assessment has to be done early enough to shape the specification, the designation of a procurement as high risk, and the information you ask bidders to supply. Downstream, exclusion grounds and enhanced due diligence give commercial teams tools to act when something is found rather than simply recording a concern.

What changed in the February 2025 update

The note is explicit that the update does not constitute a change in policy or a new call for action. Its purpose is to reflect the new terminology introduced by the Procurement Act 2023 and the Procurement Regulations 2024. Those apply to procurements commenced on or after 24 February 2025, and the note points readers to the Procurement Act 2023 guidance on transitional and savings arrangements for the meaning of commenced.

This creates a clean split for practitioners. The Procurement Act 2023 does not apply to procurements commenced before 24 February 2025, nor to contracts awarded before that date, including awards made through frameworks, dynamic purchasing systems or qualification systems established under the previous legislation. For that earlier population, PPN 009 tells readers to refer to PPN 02/23, the February 2023 action note that PPN 009 succeeds on this topic.

Because the policy itself has not moved, the note confirms that in-scope organisations do not need to repeat actions which were required when the PPN was first published. What they should do is continue to apply any ongoing obligations set out in its provisions, and note those provisions from 24 February 2025.

Applying it in practice

In practical terms an organisation needs a defensible way of designating procurements as high risk, a consistent set of supply chain information requirements for those designated procurements, and a record of the due diligence performed. The named sectors of concern are a useful starting filter, but the note frames them as examples of current global risk rather than an exhaustive list, so category knowledge still matters.

The reference to using existing exclusion grounds more effectively is the part most often left on the shelf. Exclusion is only usable if the evidence supporting it has been gathered and recorded in a form that survives challenge. That means capturing what was asked, what the supplier answered, what was checked and what conclusion was reached, at the time rather than retrospectively.

Existing contracts are explicitly in scope, which is where most organisations have the least structure. Contract managers need a route to raise concerns, a schedule for revisiting risk in the highest exposure contracts, and a way of evidencing that the supply chain information they hold is current rather than a snapshot taken at award.

How eSourcing Data helps

The requirements in PPN 009 are, in operational terms, requirements about evidence. eSourcing Data gives buying teams a single place to run competitions and hold the record behind them, so the risk designation, the supply chain information requested from bidders and the assessment of their responses sit in one audit trail rather than across mailboxes and spreadsheets. When a decision is questioned months later, the reasoning is retrievable.

The same applies to supplier management after award. Supplier records, questionnaire responses and contract documentation can be kept together and revisited, which supports the note's expectation that risks are managed in existing contracts and not only at competition stage. Reporting across categories makes it easier to see where exposure to sectors of concern such as textiles, PPE and electronics actually sits in your portfolio.

For below threshold and lower value activity, structured workflows keep proportionate checks in place without turning every small purchase into a full due diligence exercise. The aim is a consistent, recorded process that scales with risk, which is exactly the shape of the approach PPN 009 asks in-scope organisations to take.

What to do about it

1. 1Read PPN 009 alongside its accompanying guidance and confirm whether your organisation is in scope or is choosing to adopt the approach voluntarily.
2. 2Update your risk assessment characteristics so they reflect current sectors of concern, including cotton, PPE and polysilicon.
3. 3Define how a procurement is designated as high risk of modern slavery, and who signs that designation off.
4. 4Build the supply chain information requirement into the documentation for procurements designated as high risk.
5. 5Set out an enhanced due diligence process, including what evidence is gathered and where it is stored.
6. 6Review how exclusion grounds are applied so that decisions rest on recorded, contemporaneous evidence.
7. 7Extend the approach to existing contracts, with a schedule for revisiting the highest risk ones.